Gilbertson v. Williams Dingmann, LLC, 894 N.W.2d 148

Shannon Gilbertson, a licensed mortician, resigned effective Dec. 31, 2011 due to on-call schedule conflicts; she was injured at work on Oct. 13, 2011 and stopped working that day.
A Qualified Rehabilitation Consultant (QRC) prepared an R-2 Rehabilitation Plan signed by Gilbertson, employer (Williams Dingmann, LLC), and insurer; the Plan listed the vocational goal: return to work with a different employer in the same industry.
In June 2012 Dingmann offered Gilbertson a funeral-director position at the same pay and schedule as her pre-injury job, with accommodations for physical restrictions but not for her family/on-call concerns. Gilbertson declined.
Dingmann gave notice to discontinue temporary total disability (TTD) benefits; the compensation judge granted discontinuance, applying a “gainful employment” standard.
The Workers’ Compensation Court of Appeals reversed, holding the offer was not "consistent with" the filed Rehabilitation Plan and thus TTD could not be discontinued; the Minnesota Supreme Court affirmed.

Issue	Gilbertson's Argument	Dingmann's Argument	Held
Whether an employer's offer to return the employee to the same (date‑of‑injury) employer is "consistent with" a filed rehabilitation plan whose vocational goal is return to work with a different employer	The offer is inconsistent because the Rehabilitation Plan specifically lists "different employer" as the vocational goal; therefore refusal does not permit termination of TTD benefits	Consistency should be judged by totality of circumstances; an offer that meets physical restrictions and restores pre‑injury status is consistent despite the plan box marked "different employer"	The plain meaning of "consistent with" requires compatibility with the filed plan; because the Plan’s vocational goal was return to a different employer, the employer’s offer to return to the same employer was not "consistent," so TTD discontinuance was improper.

Reider v. Anoka-Hennepin Sch. Dist. No. 11, 728 N.W.2d 246 (Minn. 2007) (de novo review for statutory interpretation in workers’ compensation context)
Ekdahl v. Indep. Sch. Dist. No. 213, 851 N.W.2d 874 (Minn. 2014) (WCCA decisions applying statute to undisputed facts are not binding)
Wirtjes ex rel. Greenfield v. Interstate Power Co., 479 N.W.2d 713 (Minn. 1992) (rehabilitation directed toward restoring pre‑injury employment status and ending benefits)
Caldas v. Affordable Granite & Stone, Inc., 820 N.W.2d 826 (Minn. 2012) (when statute is clear, courts enforce plain language)
Shire v. Rosemount, Inc., 875 N.W.2d 289 (Minn. 2016) (rejecting interpretations contrary to a statute’s plain meaning)